Pre-Submission Draft Joint Core Strategy - HABITATS REGULATIONS ASSESSMENT REPORT - Gloucester
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APPENDIX 3
Gloucester, Cheltenham & Tewkesbury
Pre-Submission Draft Joint Core Strategy
HABITATS REGULATIONS ASSESSMENT REPORT
March 2014
HABITATS REGULATIONS ASSESSMENT
SCREENING REPORT
Gloucester City, Cheltenham Borough and Tewkesbury
Councils Pre-Submission Draft Joint Core Strategy
Prepared for: Gloucester City, Cheltenham Borough and Tewkesbury
Councils
date: March 2014
prepared for: Gloucester City, Cheltenham Borough and Tewkesbury
Councils
prepared by: Samantha Langford-Holt Enfusion
Alastair Peattie
quality Alastair Peattie Enfusion
assurance:
Treenwood House
Rowden Lane
Bradford on Avon
BA15 2AU
t: 01225 867112
www.enfusion.co.ukCONTENTS PAGE
EXECUTIVE SUMMARY i - iii
1 INTRODUCTION 1
Background 1
Consultation 2
Purpose and Structure of Report 2
2 HABITATS REGULATIONS ASSESSMENT (HRA) & THE PLAN 4
Requirement for Habitats Regulations Assessment (HRA) 4
Guidance and Good Practice 4
Joint Core Strategy - Key Proposals 6
3 SCREENING OF DRAFT JCS 2013 9
Previous Screening Work 9
Screening the Pre-Submission Draft JCS 2014 14
4 APPROPRIATE ASSESSMENT 31
Air Quality 31
Disturbance 39
Water Levels & Quality 43
5 HRA CONCLUSIONS 49
HRA Screening 49
HRA Appropriate Assessment 49
Consultation and Further Work 51
BIBLIOGRAPHY 52
APPENDICES
I European Site Characterisations
II Plans, Programmes and Projects Review
III Pre-Submission Draft JCS Policy Screening
IV European Site Screening
V Consultation Responses on Previous HRAGloucester, Cheltenham & Tewkesbury Draft Joint Core Strategy
HRA Report
EXECUTIVE SUMMARY
0.1 This report outlines the methods used and the findings arising from the
HRA for the Pre-Submission Draft JCS for Gloucester City, Cheltenham
Borough and Tewkesbury Borough Councils. The HRA of the JCS has
been undertaken in accordance with available guidance and good
practice and has been informed by the HRA screening work and
findings produced for earlier iterations of the JCS (2011), as well as
advice received from Natural England and Countryside Council for
Wales (now Natural Resources Wales).
HRA Screening
0.2 The first stage of the HRA process (screening) considered the likely
significant effects on fourteen European sites within the influence the
JCS. The screening process considered the potential impacts arising as
a result of the policies and whether these have the potential to lead to
likely significant effects (LSE). The screening identified five Pre-
Submission Draft JCS Policies for which the impacts could potentially
lead to significant effects alone. The six Pre-Submission Draft JCS
Policies and their potential impacts were then screened against each
of the European sites scoped into the HRA. This included consideration
of the environmental pathways and sensitivities of the sites, as well as
mitigation provided by Policies. The further screening found that for
the majority of the European sites, there were unlikely to be any
significant effects alone as a result of the Pre-Submission Draft JCS.
However, uncertainty was identified with regard to short range and
diffuse atmospheric pollution impacts as well as recreational impacts
both alone and in-combination on the Cotswold Beechwoods SAC.
Furthermore, the screening also identified uncertainty with regard to
the potential for significant in-combination effects on six European sites
as a result of changes to water levels and/ or as a result of changes to
water quality. Based on the precautionary approach these uncertain
issues were considered in more detail through AA.
HRA Appropriate Assessment (AA)
0.3 The AA considered the potential for the Pre-Submission Draft JCS to
have adverse effects on the integrity of identified European sites in
combination with other plan/ programs and projects through changes
to air quality, increased disturbance (recreational activity) and
reduced water levels and quality. It also considered the potential for
adverse effects alone with regard to air quality and disturbance on the
Cotswold Beechwoods SAC.
Air Quality
0.4 The AA found that while it is unlikely that there would be significant
effects on the Cotswolds Beechwoods SAC as a result of increased
atmospheric pollution (both alone and in-combination) given the
mitigation provided through JCS policies above, there is still an
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element of uncertainty given the lack of existing information. However,
it was concluded that this uncertainty is addressed in the JCS through
the further mitigation provided by Policies INF7 (Infrastructure Delivery)
and Policy INF8 (Developer Contributions. These policies provide a
mechanism to require financially contribute from developers towards
the protection and enhancement environmental assets, which
includes the Cotswolds Beechwoods SAC. It was therefore concluded
that the mitigation provided through Pre-Submission Draft JCS policies
and available at the project level will address the potential for adverse
effects both alone and in-combination on the Cotswolds Beechwoods
SAC as a result of increased atmospheric pollution.
Disturbance
0.5 The AA considered that determining the significance of increased
disturbance on European sites is complex and dependent on a variety
of factors including the sensitivity of designated features and the level
of their exposure to recreational activities. Pre-Submission Draft JCS
policies seek protect and enhance European sites as well as provide
open space and areas for recreation. The plan contains strong
policies on Green Infrastructure that require development to conserve
and enhance GI assets in order to deliver a series of multifunctional,
linked green corridors across the JCS area. It also requires existing GI
assets to be retained (where appropriate), improved and better
managed, and new features to be created. This includes requiring
developer contributions for such provision (for example, a contribution
towards the management of the Cotswolds Beechwoods SAC).
Policies INF7 and INF8 gives the Council’s the ability to secure financial
contributions from developers that would go towards the
management of the Cotswolds Beechwoods SAC to address any
potential increase in recreation.
0.6 Whilst there will need to be further detailed discussions between the
Council’s and NE with regard to financial contributions from developers
and the management of the SAC, the mechanisms are in place at a
strategic policy level to deliver them. It was therefore concluded that
the mitigation provided through Pre-Submission Draft JCS policies and
available at the project level will address the potential for adverse in-
combination effects on the Cotswolds Beechwoods SAC as a result of
increased recreational activity.
Water Levels and Quality
0.7 The AA assessed that the mitigation provided by Pre-Submission Draft
JCS Policies and current regulatory processes (EA Review of Consents)
would ensure that the potential impacts of proposed development on
the water environment would be minimised. In addition one
recommendation was made to improve the current baseline to
provide further evidence to demonstrate that there are unlikely to be
any significant effects with regard to water levels and quality:
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In addition to the Infrastructure Development Plan, it
recommended that a water cycle study is carried out to fully assess
the impacts of the plan on the water environment as a whole in
combination with other plans and programmes.
0.8 Given the mitigation provided by Draft JCS Policies, current regulatory
processes (EA Review of Consents) and taking into account the
recommendations above, it is assessed that the Pre-Submission Draft
JCS will not have adverse in-combination effects on the integrity of the
identified European sites through reduced water levels or water quality.
Consultation and Further Work
0.9 These findings will be subject to further consultation comments and
advice from NE and wider stakeholders. HRA is an iterative process
and further work will be undertaken alongside the JCS to inform its
development.
0.10 The findings of this plan level HRA do not obviate the need to
undertake HRA for lower level, project scale/ implementation plans
where there is potential for significant effect on one or more European
sites. The findings of this HRA should be used to inform any future
assessment work.
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1.0 INTRODUCTION
1.1 Gloucester City Council, Cheltenham Borough Council and
Tewkesbury Borough Councils (the ‘Councils’) are producing a Joint
Core Strategy (JCS) that will provide the planning framework that
guides development in the area up to 2031. The JCS sets out the
spatial vision, strategic objectives, development strategy and policies,
of the planning framework for the area, having regard to the
Community Strategies.
1.2 Enfusion has been commissioned to progress the Habitats Regulations
Assessment (HRA) of the JCS on behalf of the Councils in their role as
the competent authority. At the same time Enfusion was also
commissioned to undertaken Sustainability Appraisal (incorporating
Strategic Environmental Assessment [SEA]) of the JCS and this work has
been undertaken concurrently, with the two processes informing each
other as appropriate.
Background
1.3 The HRA process for the plan began in 2011, when a Habitats
Regulation Scoping Assessment Report was produced. The JCS
Habitats Regulation Scoping Assessment Report was placed on a five
week consultation period during April and May 2011. Comments were
received from NE and CCW (now Natural Resources Wales (NRW)) and
helped to inform the final version of the JCS Habitats Regulation
Scoping Assessment which was published in July 2011. It was
concluded that more assessment would be required once further
policy detail was available.
1.4 Further work was carried out on the JCS and a Developing the
Preferred Option Consultation Document was produced and then
published in December 2011. The consultation document set out the
vision for the JCS area to 2031 as well as a number of options for how it
could be achieved. This included the potential employment and
housing requirements for the JCS area as well as a number of strategic
allocations. Options for broad locations to deliver development
requirements post 2021 across the JCS area were also identified.
Building on the findings of the Habitats Regulation Scoping Assessment
Report (July 2011) further screening assessment work was undertaken
for the Preferred Option Consultation Document. The work was
presented in an HRA Screening Report that accompanied the
Preferred Option Consultation Document on a six week consultation in
December 2011. The JCS vision, strategic objectives, strategic
development management policies and a number of spatial
development scenarios were considered through the screening
assessment.
1.5 Following the consultation on the Preferred Option in December 2011 a
number of changes were made to the JCS including: new housing and
employment targets; a urban focused spatial development strategy;
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an amended vision and strategic objectives; new and amended
policies complete with firm urban extension and strategic allocation
sites to accommodate major development. The updated plan was
called the Draft JCS 2013 and further HRA screening work and then AA
was carried out on this iteration of the Plan in October 2013. The
findings of the HRA were subject to consultation alongside the Draft
JCS 2013 between October and December 2013.
1.6 Between December 2013 and March 2014, as a result of public
consultation, the JCS has undergone a number of changes. These
include new housing and employment targets lower than previously
considered - 30,500 new homes and land to support 28,000 new jobs -
as well as amended policies with more robust mitigation in relation to
water quality, green infrastructure, and infrastructure provision in
general. In addition, one urban extension in Cheltenham has been
removed and another in Gloucester reduced in size by almost half.
1.7 The assessment and findings presented in the Draft JCS HRA Report
(Oct 2013) have been revised and updated to ensure that the
changes to the JCS have been sufficiently considered through the HRA
process. The work set out in this Report builds on the previous HRA
screening and AA work undertaken. Consultation responses received
on the Draft JCS HRA Report (Oct 2013) have also informed the further
HRA work.
Consultation
1.8 The Habitats Regulations require the plan making/competent authority
to consult the appropriate nature conservation statutory body. Given
the proximity to Wales and the potential far reaching effects of
European sites, in this case both Natural England and Natural
Resources Wales (NRW) will be consulted.
1.9 Comments from the statutory nature conservation bodies were
received on the HRA Scoping Report (July 2011), the HRA Screening of
the Gloucester, Cheltenham and Tewkesbury JCS ‘Developing the
Preferred Option Consultation Document (Dec 2011) and the Draft JCS
HRA Report (October 2013). These comments and any advice
provided have been taken forward in the iterative HRA work
documented in this Report.
1.10 The Habitats Regulations leave consultation with other bodies and the
public to the discretion of the plan making authority. Therefore, in
addition to the statutory consultation undertaken with the appropriate
nature conservation bodies, this HRA (AA) Report is available for wider
public consultation alongside the Pre-Submission Draft JCS.
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Purpose & Structure of Report
1.11 This report documents the process and the findings of the HRA for the
JCS. Following this introductory section the document is organised into
a further four sections:
Section 2 summarises the requirement for HRA and the background
to the Joint Core Strategy.
Section 3 outlines the screening process and the findings of the
screening assessment.
Section 4 outlines the AA process and the findings of the assessment,
including avoidance and mitigation measures where necessary.
Section 5 summarises the findings of the HRA and sets out the next
steps.
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2.0 HABITATS REGULATIONS ASSESSMENT (HRA) AND THE
PLAN
Requirement for Habitats Regulations Assessment
2.1 The Conservation of Habitats and Species Regulations 2010 (as
amended) [the Habitats Regulations] require that HRA is applied to all
statutory land use plans in England and Wales. The aim of the HRA
process is to assess the potential effects arising from a plan against the
conservation objectives of any site designated for its nature
conservation importance.
2.2 The Habitats Regulations transpose the requirements of the European
Directive (92/43/EEC) on the Conservation of Natural Habitats and Wild
Flora and Fauna [the Habitats Directive] which aims to protect habitats
and species of European nature conservation importance. The
Directive establishes a network of internationally important sites
designated for their ecological status. These are referred to as Natura
2000 sites or European Sites, and comprise Special Areas of
Conservation (SACs) and Special Protection Areas (SPAs) which are
designated under European Directive (2009/147/EC) on the
conservation of wild birds [the Birds Directive]. In addition,
Government guidance also requires that Ramsar sites (which support
internationally important wetland habitats and are listed under the
Convention on Wetlands of International Importance [Ramsar
Convention]) are included within the HRA process as required by the
Regulations.
2.3 The process of HRA is based on the precautionary principle and
evidence should be presented to allow a determination of whether the
impacts of a land-use plan, when considered in combination with the
effects of other plans and projects against the conservation objectives
of a European Site; would adversely affect the integrity of that site.
Where effects are considered uncertain, the potential for adverse
impacts should be assumed.
Guidance and Good Practice
2.4 The application of HRA to Local Plans is an emerging field and has
been informed by a number of key guidance and practice documents.
Draft guidance for HRA ‘Planning for the Protection of European Sites:
Appropriate Assessment’, was published by the Government (DCLG,
2006) and is based on the European Commission’s (2001) guidance for
the Appropriate Assessment of Plans. The DCLG guidance
recommends three main stages to the HRA process:
Stage 1: Screening for Likely Significant Effect
Stage 2: Appropriate Assessment, Ascertaining Effects on Integrity
Stage 3: Mitigations Measures and Alternatives Assessment.
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2.5 If alternative solutions or avoidance/ mitigation measures to remove
adverse effects on site integrity cannot be delivered then current
guidance recommends an additional stage to consider Imperative
Reasons of Overriding Public Interest (IROPI) for why the plan should
proceed. For the HRA of land use plans IROPI is only likely to be justified
in a very limited set of circumstances and must be accompanied by
agreed, deliverable compensation measures for the habitats and
species affected. For this reason the IROPI stage is not detailed further
in this report.
2.6 More recently Natural England has produced additional, detailed
guidance on the HRA of Local Development Documents (Tyldesley,
2009 (as updated)) that complements the DCLG guidance, and builds
on assessment experience and relevant court rulings. The guidance:
sets out criteria to assist with the screening process; addresses the
management of uncertainty in the assessment process; and
importantly outlines that for the HRA of plans; ‘ … what is expected is
as rigorous an assessment as can reasonably be undertaken in
accordance with the requirements of the Regulations …’.
2.7 The approach taken for the HRA of the Draft JCS follows the method
set out in formal guidance documents.
2.8 The key stages of the HRA process overall, and the specific tasks
undertaken for each stage are set out in Table 2.1.
Table 2.1: Habitats Regulations Assessment: Key Stages
Stages Habitats Regulations Assessment
Stage 1: 1. Identify European sites in and around the plan area.
Screening 2. Examine the conservation objectives of each interest feature of the
for Likely European site(s) potentially affected.
significant 3. Analyse the policy/ plan and the changes to environmental
Effects conditions that may occur as a result of the plan. Consider the extent
of the effects on European sites (magnitude, duration, and location)
based on best available information.
4. Examine other plans and programmes that could contribute
(cumulatively) to identified impacts/ effects.
5. Produce screening assessment based on evidence gathered and
consult statutory nature conservation body on findings.
6. If effects are judged likely or uncertainty exists – the precautionary
principle applies proceed to Stage 2.
Stage 2: 1. Agree scope and method of Appropriate Assessment with statutory
Appropriate nature conservation body.
Assessment 2. Collate all relevant information and evaluate potential impacts on
site(s) in light of conservation objectives.
Stage 3: 1. Consider how effect on integrity of site(s) could be avoided by
Mitigation changes to plan and the consideration of alternatives (e.g. an
Measures alternative policy/ spatial location). Develop mitigation measures
and (including timescale and mechanisms for delivery).
Alternatives 2. Prepare HRA/ AA report and consult statutory body.
Assessment 3. Finalise HRA/AA report in line with statutory advice to accompany
plan for wider consultation.
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Pre-Submission Draft Joint Core Strategy - Key Proposals
2.9 The JCS sets out to the preferred strategy to accommodating
development. The objectives of the JCS are aligned with the
community ambitions in the 3 local authorities’ adopted Sustainable
Community Strategies that set out the long-term ambitions for the
communities. The JCS sets out the key challenges for the JCS area and
a Vision for the development of the area until 2031. This is followed by
Strategic Objectives to deliver the Vision for the area and these
objectives have been grouped under the headline aims of the 3
Sustainable Community Strategies:
A thriving economy
A sustainable natural and built environment
A healthy, safe and inclusive community
2.10 Chapter 3 of the JCS contains a number of strategic policies for the
sub-areas of Gloucester, Cheltenham and Tewkesbury, including
strategic proposals for housing and employment development in
broad locations. Chapter 4 presents a number of Sustainable
Development Policies grouped within the key ambitions of the
Strategic Community Strategies. Chapter 5 contains the Infrastructure
Policies and Chapter 6 is concerned with the Strategic Allocation
Policies Chapter 7 sets out how the objectives and policies of the plan
will be monitored and reviewed.
2.11 The Vision and the Strategic Objectives for the Pre-submission Draft JCS
are as follows:
GCT JCS Vision
By 2031 Tewkesbury Borough, Cheltenham Borough and Gloucester
City will have continued to develop as highly attractive and highly
accessible places in which to live, work and socialize.
The Joint Core Strategy area will be recognized nationally as enjoying
a vibrant, competitive economy with increased job opportunities and
a strong reputation for being an attractive place in which to invest.
The character and identity of individual communities will have been
retained while improved access to housing will have addressed the
needs of young families, single people and the elderly.
New developments will have been built to the highest possible
standards of design and focused protecting the quality and
distinctiveness of each community.
Established in sustainable locations, without increasing the risk of
flooding, new development will have been designed with sensitivity
towards existing villages, towns and cities and with respect for the
natural environment.
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As a result of a strong commitment to the housing and employment
needs of the existing and growing population, all residents and
businesses will benefit from the improved infrastructure, which will
include roads, public transport and services, and community facilities.
JCS Strategic Objectives:
JCS Strategic Objective 1: Building a strong and competitive economy
JCS Strategic Objective 2: Ensuring vitality of town centres
JCS Strategic Objective 3: Supporting a prosperous rural economy
JCS Strategic Objective 4: Conserving and enhancing the environment
JCS Strategic Objective 5: Delivering excellent design in new
developments
JCS Strategic Objective 6: Meeting the challenge of climate change
JCS Strategic Objective 7: Promoting sustainable transport
JCS Strategic Objective 8: Delivering a wide choice of quality homes
JCS Strategic Objective 9: Promoting healthy communities
2.12 The JCS is based on collaborative research into the three council
areas' characteristics, relationships (with each other and adjoining
areas), past trends and future predictions. The most recent research
on the Objectively Assessed need (OAN) indicates that there will be a
need for 30,500 new homes and between 28,000 new jobs over the
period to 2031.
2.13 Taking into account the likely employment and housing needs, the
emerging JCS identified a preferred strategy for distributing
development through an Urban Focus. This means that the
development will be distributed in the existing urban areas mainly in
Gloucester, Cheltenham and Tewkesbury and in urban extensions and
strategic allocations set out in Policy SA1.
2.14 The Pre-Submission Draft JCS includes policies which set out the
strategic locations for and the requirements that development in the
JCS area will have to meet. A list of the policies is provided below:
STRATEGIC POLICIES
Policy SP1 – Scale of New Development
Policy SP2 – Distribution of New Development
SUSTAINABLE DEVELOPMENT POLICIES
Policy SD1 – Presumption in Favour of Sustainable Development
Policy SD2 – Employment
Policy SD3 – Retail Hierarchy and Town Centres
Policy SD4 – Sustainable Design and Construction
Policy SD5 – Design Requirements
Policy SD6 – Green Belt
Policy SD7 – Landscape
Policy SD8 – Cotswolds Area Of Outstanding Natural Beauty
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Policy SD9 – Historic Environment
Policy SD10 – Biodiversity and Geodiversity
Policy SD11 – Residential Development
Policy SD12 – Housing Mix and Standards
Policy SD13 – Affordable Housing
Policy SD14 – Gypsies, Travellers and Travelling Showpeople
Policy SD15 – Health and Environmental Quality
INFRASTRUCTURE POLICIES
Policy INF1 – Access to the Transport Network
Policy INF2 – Safety and Efficiency of the Transport Network
Policy INF3 – Flood Risk Management
Policy INF4 – Green Infrastructure
Policy INF5 – Social and Community Infrastructure
Policy INF6 – Renewable Energy/Low Carbon Energy Development
Policy INF7 – Infrastructure Delivery
Policy INF8 – Developer Contributions
STRATEGIC ALLOCATIONS
Policy SA1 –Strategic Allocations Policy
Strategic Allocations Information
Overview of Plan Area
2.15 The Pre-Submission Draft JCS covers the local authority areas of
Gloucester City, Cheltenham Borough and Tewkesbury Borough and its
spatial extent is shown in the Figure 2.1 below.
Figure 2.1: Map of JCS Area
*Sourced: Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils, 2013
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3.0 SCREENING
3.1 As detailed in Section 2, Table 2.1, HRA typically involves a number of
stages. This section of the report sets out the approach and findings for
Stage 1, HRA Screening for the Pre-Submission Draft JCS. The aim of
the screening stage is to assess in broad terms whether the policies and
proposals set out in the plan are likely to have a significant effect on a
European site(s), and whether in the light of available avoidance and
mitigation measures, an Appropriate Assessment (AA) is necessary.
Previous Screening Work
3.2 It was noted in Section 1 that a high level HRA Screening was first
undertaken in early 2011 for the JCS. The JCS Habitats Regulation
Scoping Assessment Report was placed on a five week consultation
period during April and May 2011. Comments were received from NE
and CCW (now Natural Resources Wales (NRW)) and helped to inform
the final version of the JCS Habitats Regulation Scoping Assessment
which was published in July 2011.
3.3 The report concluded that it was not possible to make precise
judgments about the likely significant effects of the JCS at that stage
given the lack of policy detail available. However, it did identify some
areas to focus on, which included the general location and quantum
of proposed development. The potential impacts identified were as
follows:
Direct - During construction, noise, lighting, increased traffic.
Pollution in the air (mainly nitrogen) is a key concern through
polluting stack emissions.
Air pollution from increase in traffic.
Direct - dust arising during construction.
Hydrological links – siltation could occur through connecting
watercourses to the estuarine sites.
Direct - development could provide further perches for predators.
Direct - from large scale industry or waste facility which would
produce toxic contaminants.
Hydrological links - leachate, surface run off and groundwater
infiltration from development sites could potentially enter European
river sites during site construction and operation.
Disturbance to bats, roost and supporting woodland.
Indirect - Development could interrupt flight lines.
3.4 It was concluded that more assessment would be required once
further policy detail was available.
3.5 Further work was carried out on the JCS and a Developing the
Preferred Option Consultation Document was produced and then
published in December 2011. The consultation document set out the
vision for the JCS area to 2031 as well as a number of options for how it
could be achieved. This included the potential employment and
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housing requirements for the JCS area as well as a number of strategic
allocations. Options for broad locations to deliver development
requirements post 2021 across the JCS area were also identified.
3.6 Building on the findings of the Habitats Regulation Scoping Assessment
Report (July 2011) further screening assessment work was undertaken
for the Preferred Option Consultation Document. The work was
presented in an HRA Screening Report that accompanied the
Preferred Option Consultation Document on a six week consultation in
December 2011. The JCS vision, strategic objectives, strategic
development management policies and a number of spatial
development scenarios were considered through the screening
assessment.
3.7 The HRA Screening of the JCS Preferred Option Consultation Document
assessed that likely significant effects on the integrity of certain
European sites for each of the development scenarios could not be
ruled out, either alone or in-combination. The findings of the screening
assessment for the four development scenarios are presented in Table
3.1.
Table 3.1: Summary of likely significant effects in the HRA Screening of
the JCS Preferred Option Consultation Document (LUC, 2011)
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3.8 The screening concluded that although the development scenarios
have the potential to adversely impact European sites, some if not all
of these effects may be rules out with more detailed understanding
and research of the sensitivity of the sites and current management
arrangements. Natural England’s response to the Screening Report
indicated that the scope and the overall conclusions of the HRA were
appropriate (see Appendix V).
Screening the Draft JCS 2013
3.9 Following the consultation on the Preferred Option in December 2011
there were a number of changes made to the JCS which included:
New housing and employment targets – 33,200 new homes and
land to support 21,800 new jobs;
An urban focused spatial development strategy - development will
be distributed in the existing urban areas mainly in Cheltenham,
Gloucester and Tewkesbury and in urban extensions and strategic
allocations. Rural Service Centres and Service Villages will
accommodate approximately 2740 new homes;
An amended vision and strategic objectives – including an
objective relating specifically to conserving and enhancing the
environment; and
New and amended policies complete with firm urban extension
and strategic allocation sites to accommodate major
development.
3.10 Building on the previous screening work and informed by the
consultation responses received the screening tasks (Table 2.1) were
revisited for the JCS.
Identification of European Sites
3.11 The HRA Scoping Report (July 2011) considered that the following sites
should be included in the HRA of the JCS, which was agreed with NE
and CCW:
Sites wholly or partly within the JCS boundaries
Cotswold Beechwoods SAC
Dixton Wood SAC
Sites outside the JCS boundaries
Bredon Hill SAC
Lyppard Grange Ponds SAC
River Wye SAC
Rodborough Common SAC
Severn Estuary SAC, SPA and Ramsar
Walmore Common SPA and Ramsar
Wye Valley and Forest of Dean Bat Sites SAC
Wye Valley Woodlands SAC
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3.12 In response to the HRA Scoping Report CCW requested that sites at
even greater distance be considered where there is a potential
pathway for significant effects to take place. Plans such as the JCS
can have spatial implications that extend beyond the intended plan
boundaries. In particular, it is recognised that when considering the
potential for effects on European sites, distance in itself is not a
definitive guide to the likelihood or severity of an impact. Other factors
such as inaccessibility/ remoteness, the prevailing wind direction, river
flow direction, and ground water flow direction will all have a bearing
on the relative distance at which an impact can occur. This means
that a plan directing development some distance away from a
European Site could still have effects on the site and therefore, needs
to be considered as part of the HRA screening.
3.13 To address CCW’s comment, the HRA Screening Report (Dec 2011)
included the River Usk SAC within the scope of the HRA for the JCS as it
is connected to the River Wye via the South East Wales Conjunctive
Use Scheme. Based on the proposed development set out in the JCS
Developing the Preferred Option, the scope set out in the HRA
Screening Report (Dec 2011) is still considered appropriate for the HRA
of the JCS. The HRA Screening report (Dec 2011) concluded that the
JCS would not have significant effects on Bredon Hill SAC and Lyppard
Grange Ponds SAC; however, given the further detail available with
regard to proposed development these European sites have been
included in the further screening work to ensure that there are no
adverse effects. The European sites scoped into the screening work in
2013 are set out in Table 3.2 below.
Table 3.2: European Sites within HRA Scope
European Site Designation
European Sites within Plan Area
Cotswold Beechwoods SAC
Dixton Wood SAC
European Sites outside Plan Area
Bredon Hill SAC
Lyppard Grange Ponds SAC
River Usk SAC
River Wye SAC
Rodborough Common SAC
Severn Estuary SAC/ SPA/ Ramsar
Walmore Common SPA/ Ramsar
Wye Valley and Forest of Dean Bat Sites SAC
Wye Valley Woodlands SAC
3.14 The first stage in the screening process considered the potential
impacts arising as a result of the policies and whether these have the
potential to lead to likely significant effects (LSE). The screening
identified eleven Draft JCS Policies for which the impacts could
potentially lead to significant effects alone. The eleven Draft JCS
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Policies and their potential impacts were then screened against each
of the European sites scoped into the HRA. This included consideration
of the environmental pathways and sensitivities of the sites, as well as
mitigation provided by Draft JCS Policies. The key findings are
summarised below.
Table 3.3: HRA Screening Summary
Potential Likely Significant Effects
Habitat Loss & Fragmentation
Water Levels & Quality
Disturbance
Air Quality
European sites
A1 IC2 A IC A IC A IC
European sites within DRAFT JCS area
Cotswold Beechwoods SAC ? ? No ? No ? No No
Dixton Wood SAC No No No No No No No No
European sites outside DRAFT JCS area
Bredon Hill SAC No No No No No No No No
Lyppard Grange Ponds SAC No No No No No ? No No
River Usk SAC No No No No No ? No No
River Wye SAC No No No No No ? No No
Rodborough Common SAC No No No No No No No No
Severn Estuary SAC/ SPA/ No No No No No ? No No
Ramsar
Walmore Common SPA/ No No No No No ? No No
Ramsar
Wye Valley and Forest of No No No No No No No No
Dean Bat Sites SAC
Wye Valley Woodlands SAC No No No No No ? No No
1 AA required alone?
2 AA required in combination?
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Table 3.4: Screening Summary Key
Likely Significant Effect Yes Appropriate Assessment required
No Likely Significant Effect No No further assessment required
Significant Effect Uncertain ? Uncertain, precautionary approach
taken and Appropriate Assessment
required
3.15 The screening assessment identified uncertainty with regard to the
potential for significant effects on seven European sites as a result of
changes to air quality, increased disturbance; changes to water levels
and/ or water quality. Based on the precautionary approach these
issues were considered in more detail through AA. The findings of the
HRA (AA) Report 2013 were subject to consultation between October
and December 2013. The responses received have been included in
Appendix V of this HRA Report.
Screening the Pre-Submission Draft JCS 2014
3.16 Since the consultation on the Draft JCS 2013 there have been a
number of changes made to the JCS which include:
New housing and employment targets - with lower housing
requirements at 30,500 new homes and a higher level of job growth
at 28,000 new jobs;
Amended policies with more robust mitigation in relation to water
quality, green infrastructure, infrastructure provision in general
referring specifically to Green space and environmental assets. In
addition, one urban extension in Cheltenham has been removed
and another in Gloucester reduced in size by almost half.
The removal of the South Cheltenham – Up Hatherley Urban
Extension and the reduction in size and capacity of the Innsworth
Urban Extension.
3.17 It is therefore necessary to revisit the screening tasks (Table 2.1) for the
JCS. This work will build on the previous HRA screening work
undertaken in 2011 and 2013.
Identification of European Sites
3.18 The European sites scoped into the HRA in 2013 are still considered
appropriate for the further screening work for the Pre-Submission Draft
JCS. No further comments have been received from statutory
consultees with regard to the scope of the HRA and the changes to
the JCS are not considered likely to significantly affect the European
sites scoped in. The European sites scoped into the HRA for the JCS are
set out in Table 3.5 below and presented in Figure 3.1.
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Table 3.5: European Sites within HRA Scope
European Site Designation
European Sites within Plan Area
Cotswold Beechwoods SAC
Dixton Wood SAC
European Sites outside Plan Area
Bredon Hill SAC
Lyppard Grange Ponds SAC
River Usk SAC
River Wye SAC
Rodborough Common SAC
Severn Estuary SAC/ SPA/ Ramsar
Walmore Common SPA/ Ramsar
Wye Valley and Forest of Dean Bat Sites SAC
Wye Valley Woodlands SAC
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Figure 3.1 - European Sites within HRA Scope
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Characterisation of European Sites
3.19 A general overview of the thirteen sites scoped into the assessment is
provided below in Figure 3.2. More detailed characterisations
including conservation objectives and the specific vulnerabilities for
each site are provided in Appendix I.
Figure 3.2: European Site Characterisations
European Sites within Plan Area
Cotswold Beechwoods SAC is situated at the southern edge of the JCS area
and covers part of Tewkesbury, plus Stroud and Cotswold Districts of
Gloucestershire. The SAC consists of ancient beech woodlands and
unimproved grassland lying over Jurassic limestone at the western edge of
the Cotswolds. The woodlands are amongst the most diverse and species
rich of their type while the grasslands typify the unimproved calcareous
pastures for which the area is famous.
Dixton Wood SAC is situated approximately 6.7km to the South East of
Tewkesbury and is an area of broadleaved woodland (formerly partially
grazed) with a dominance of ash including exceptionally large ancient
pollards. The site is designated for its population of Violet Click Beetle, which
is largely dependent on these pollards (for breeding). Principal risks to the
site's integrity are lack of future replacement pollards (age-class skewed to
older generation) and game management practices.
European Sites outside Plan Area
Bredon Hill SAC is an area of pasture woodland and ancient parkland
situated approximately 4.5km to the North East of Tewkesbury. The site
provides habitat for the Violet Click Beetle Limoniscus violaceus beetle,
which develops in the decaying wood either of very large, old hollow beech
trees (Windsor Forest) or ash trees (Worcestershire/ Gloucestershire border
sites). Currently the key site attributes which Natural England understands the
species to require is related to the abundance and condition of the ancient
trees on the designated site within which it develops.
Lyppard Grange SAC is located on the East outskirts of Worcester and is
situated amongst a recent housing development on former pastoral
farmland. The site is composed of two ponds in an area of grassland and
scrub (public open space). The site provides habitat for Great Crested Newts
Triturus cristatus, which are dependent on both the existing terrestrial habitat
(to provide foraging areas and refuge) and on the pond, aquatic habitat
(for breeding).
The River Usk SAC is entirely within Wales, rising in the Black Mountain range in
the west of the Brecon Beacons National Park and flowing east and then
south, to enter the Severn Estuary at Newport. The ecological structure and
functions of the site are dependent on hydrological and geomorphological
processes (often referred to as hydromorphological processes), as well as the
quality of riparian habitats and connectivity of habitats. Animals that move
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around and sometimes leave the site, such as migratory fish and otters, may
also be affected by factors operating outside the site. The River Usk is
important for its population of sea lamprey and supports a healthy
population of brook lamprey and river lamprey. The site supports a range of
Annex II fish species, which includes twaite shad Alosa falla, salmon Salmo
sala and bullhead Cottus gobi. The River Usk is an important site for otters
Lutra lutra in Wales.
The River Wye SAC, on the border of England and Wales, is a large river of
plain to montane levels. It has a geologically mixed catchment, including
shales and sandstones, and there is a clear transition between the upland
reaches, with characteristic bryophyte-dominated vegetation, and the lower
reaches, with extensive Ranunculus beds. There is an exceptional range of
aquatic flora in the catchment including river jelly-lichen. The river channel is
largely unmodified and includes some excellent gorges, as well as significant
areas of associated woodland. The site is also designated for its populations
of Lamprey, White-clawed crayfish, Twaite Shad, Atlantic Salmon, Bullhead
and Otter.
Rodborough Common SAC is situated approximately 8km to the south of the
JCS area in the Stroud District of Gloucestershire. The SAC is on the Cotswold
scarp on a central plateau area with steep drops on all sides. The
vegetation is unimproved herb-rich calcareous grassland.
Severn Estuary SPA/Ramsar/SAC is the largest coastal plain estuary in the UK
with extensive mudflats and sandflats, rocky shore platforms, shingle and
islands. Saltmarsh fringes the coast, backed by grazing marsh with freshwater
and occasional brackish ditches. The estuary’s classic funnel shape, unique
in the UK, is a factor causing the Severn to have the second highest tidal
range in the world (after the Bay of Fundy in Canada) at more than 12
meters. This tidal regime results in plant and animal communities typical of
the extreme physical conditions of strong flows, mobile sediments, changing
salinity, high turbidity and heavy scouring. The resultant low diversity
invertebrate communities, that frequently include populations of ragworms,
lugworms and other invertebrates in high densities, form an important food
source for passage and wintering birds. The site is important in the spring and
autumn migration periods for waders moving along the west coast of
Europe, as well as in winter for large numbers of waterbirds including swans,
geese, ducks and waders. These bird populations are regarded as
internationally important.
Walmore Common SPA/Ramsar is located in Gloucestershire, in the west of
England, about 10 km south-west of Gloucester. The site is a wetland
overlying peat providing a variety of habitats including improved neutral
grassland, unimproved marshy grassland and open water ditches. The area
is subject to regular winter flooding and this creates suitable conditions for
regular wintering by an important number of Bewick's Swan Cygnus
columbianus bewickii. The highest bird numbers are seen during the harshest
winters, when Walmore Common provides an essential feeding and roosting
area.
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Wye Valley and Forest of Dean Bat Sites SAC straddles the Wales-England
border and covers an area of 142.7ha. It is underpinned by 4 SSSI in Wales
and 9 in England, all of which lie entirely within the SAC. This complex of sites
contains by far the greatest concentration of lesser horseshoe bat in the UK,
totalling about 26% of the national population. It has been selected on the
grounds of the exceptional breeding population, and the majority of sites
within the complex are maternity roosts. The site also supports the greater
horseshoe bat in the northern part of its range, with about 6% of the UK
population. The site contains the main maternity roost for bats in this area,
which are believed to hibernate in the many disused mines in the Forest.
Wye Valley Woodlands SAC straddles the Wales–England border and covers
an area of 914ha. It is underpinned by 9 SSSIs in Wales and 7 in England, all
of which lie entirely within the SAC. The woodlands of the lower Wye Valley
form one of the most important areas for woodland conservation in Britain.
Many rare and local species are present, including some of the rarest native
tree species. These woods sit in a matrix of unimproved grassland and other
semi-natural habitats.
Effects of the Pre-Submission Draft JCS 2014
3.20 The emphasis of the Pre-submission Draft JCS is on jobs and economic
prosperity and a key element of the plan is the delivery across the plan
area of 30,500 new homes over the life of the plan (to 2031). Housing,
employment and infrastructure development has the potential to
generate a range of environmental impacts which can, (depending
on their nature, magnitude, location and duration), have effects on
European sites. A summary of the types of impacts and effects that
can arise from these types of development is provided in Table 3.6.
Table 3.6: Housing, Employment and Infrastructure Development:
Summary of Impacts and Effects on European Sites
Effects on Impact Types
European Sites
Habitat (& Direct land take, removal of green/ connecting
species) corridors/ supporting habitat, changes to sediment
fragmentation patterns (rivers and coastal locations)
and loss
Introduction of invasive species (predation)
Disturbance Increased recreational activity (population increase)
Noise and light pollution (from development and
increased traffic)
Changes to Increased abstraction levels (new housing)
hydrological
Increased hard standing non-permeable surfaces/
regime/ water
accelerated run-off
levels
Laying pipes/ cables (surface & ground)
Topography alteration
Changes to Increase in run-off/ pollutants from non-permeable
water quality surfaces (roads, built areas)
Increased air pollution (eutrophication) (traffic,
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Effects on Impact Types
European Sites
housing)
Increased volume of discharges (consented)
Changes in air Increased traffic movements
quality
Increased emissions from buildings
3.21 The first stage in the screening process considered the potential
impacts (Table 3.6 above) arising as a result of the policies and
whether these have the potential to lead to likely significant effects
(LSE). The screening identified five Pre-Submission Draft JCS Policies for
which the impacts could potentially lead to significant effects
(Appendix III) alone. The policies and their potential impacts are
provided in Table 3.7.
Table 3.7: Pre-submission Draft JCS Policies identified as having impacts
that could lead to LSE
Policy/ Potential impacts of the Policy/ Allocation
Allocation
SP1 – Scale of The Policy makes provision over the Plan period for 30,500
New new homes and land to support 28,000 new jobs. It aims to
Development deliver this through development within existing urban area
via District Plans and through urban extensions and
strategic allocations set out in Policy SA1. The allocations
have been considered separately below.
The Policy has the potential to result in:
atmospheric pollution through increased traffic, which
could reduce air quality;
increased levels of disturbance - recreational activity,
noise and light pollution;
increased levels of abstraction; surface water run-off
and sewerage discharge, which could reduce water
quality and levels; and
land take, which could lead to the loss and
fragmentation of habitats.
SP2 – Distribution The Policy sets out the broad locations and the level of
of Development development (housing and jobs) for each broad location.
Again the development is based in the existing urban area
and in urban extensions and strategic allocations A1 to A9.
The allocations have been considered separately below.
Policy has the potential to result in:
atmospheric pollution through increased traffic, which
could reduce air quality;
increased levels of disturbance - recreational activity,
noise and light pollution;
increased levels of abstraction; surface water run-off
and sewerage discharge, which could reduce water
quality and levels; and
land take, which could lead to the loss and
fragmentation of habitats.
SD6 – Green Belt The Policy seeks to protect the Green Belt from harmful
(Previously development to ensure that it continues to serve its key
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Policy/ Potential impacts of the Policy/ Allocation
Allocation
known as S5 – functions. The policy designates two sites as developed
Green Belt) sites in the Green Belt including Gloucestershire Airport and
Cheltenham Racecourse and supports developed related
to these uses on these sites. It also mentions that waste
management sites are allocated within the Green Belt but
these are being taken forward by the Gloucestershire
waste management Strategy and not being allocated
through this plan. Furthermore, two safeguarded areas
have been identified for potential future development in
the green belt: an area of land to the West of Cheltenham
and an area of land to the north west of Cheltenham.
Gloucestershire Airport
Site is just over 6km away from the Cotswold Beechwoods
SAC so unlikely to have a significant effect alone.
Norman’s Brook runs along the western edge of the site
and eventually flows into Hatherley Brook, which flows into
the River Severn. The River Severn SAC/ SPA/ Ramsar and
Walmore Common SPA/Ramsar are downstream so there
is the potential for impacts alone on water quality.
Norman’s Brook should be protected and retained and
any proposal for development should ensure that impacts
on water quality and resources are minimised.
Potential in-combination effects are considered in
Appendix IV and Section 4 of the HRA (AA) Report.
Cheltenham Racecourse
Given the type of the development (employment) and the
location of the site it is unlikely that there will be significant
effects on European sites. Similar to other potential sites
any proposal for development should seek to minimise
impacts on water quality and water resources.
Potential in-combination effects are considered in
Appendix IV and Section 4 of the HRA (AA) Report.
Land to the West of Cheltenham
Given the location of the site it is unlikely that there will be
significant effects on European sites. Similar to other
potential sites any proposal for development should seek
to minimise impacts on water quality and water resources.
Potential in-combination effects are considered in
Appendix IV and Section 4 of the HRA (AA) Report.
Land to the North West of Cheltenham
Please refer to allocation A5 below. This parcel of
safeguarded land is directly adjacent to the allocation set
out in A5 and is included as an integral part of it.
INF7 – The Policy requires that where need is generated as a
Infrastructure result of individual site proposals and/or as a consequence
Delivery of cumulative impact, new development will be served
(Previously and supported by adequate and appropriate on- and/or
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Policy/ Potential impacts of the Policy/ Allocation
Allocation
known as D1 – off-site infrastructure and services. It states that where
Infrastructure) need for additional infrastructure and services and/or
impacts on existing infrastructure and services is expected
to arise, the local planning authority will seek to secure
appropriate and proportionate infrastructure provision in
respect of in particular:
Climate change mitigation / adaptation
Community facilities
The highway network, traffic management, sustainable
transport and disabled people's access
Protection of environmental assets and the potential
for their enhancement
Provision of Green Infrastructure including open space
Priority for provision will be assessed both on a site by site
basis and having regard to the mitigation of cumulative
impact together with implementation of the JCS
Infrastructure Delivery Plan. Planning permission will be
granted only where sufficient provision has been made for
infrastructure and services (together with their continued
maintenance) to meet the needs of new development
and/or which is required to mitigate the impact of new
development upon existing communities.
This policy will generate additional development which
could result in land take which could lead to the loss and
or fragmentation of habitats. However, it generally seeks to
provide mitigation which could reduce emission to air,
increased levels and disturbance and protection of
environmental assets and the potential for their
enhancement.
SA1 –Strategic Site is over 7 km from the Cotswold Beechwoods SAC so
Allocations unlikely to have a significant effect alone. The site has one
Policy brook (Hatherley Brook) running through it which eventually
flow into the River Severn a km away. The River Severn
A1 – Innsworth SAC/ SPA/ Ramsar and Walmore Common SPA/Ramsar
(Previously are downstream so there is the potential for impacts alone
known as A1 – on water quality. The Brooks flowing through the site
Innsworth and should be protected and retained and any proposal for
Twigthworth development should ensure that impacts on water quality
Urabn Extension, and resources are minimised.
Gloucester)
Potential in-combination effects are considered in
1250 Appendix IV and Section 4 of the HRA (AA) Report.
dwellings.
9.1 ha
employment
land.
SA1 –Strategic Site is just over 6 km away from the Cotswold Beechwoods
Allocations SAC so unlikely to have a significant effect alone.
Policy Norman’s Brook runs through the site and eventually flows
into Hatherley Brook, which flows into the River Severn. The
A2 – North River Severn SAC/ SPA/ Ramsar and Walmore Common
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Policy/ Potential impacts of the Policy/ Allocation
Allocation
Churchdown SPA/Ramsar are downstream so there is the potential for
(Previously impacts alone on water quality. Norman’s Brook should be
known as A2 – protected and retained and any proposal for
North development should ensure that impacts on water quality
Churchdown and resources are minimised.
Urban Extension,
Gloucester) Potential in-combination effects are considered in
Appendix IV and Section 4 of the HRA (AA) Report.
530
dwellings
SA1 –Strategic Site is approximately 2 km away from the Cotswold
Allocations Beechwoods SAC; need to consider potential impacts of
Policy development on the A46 which runs adjacent to the SAC.
Potential for increased levels of atmospheric pollution as
A4 – North the A46 is within 200m of the SAC. Will require further
Brockworth investigation on the sensitivity of the SAC to recreational
(Previously activity. Horsbere Brook runs along the boundary of the
known as A4 – site and eventually flows into the River Severn. The River
North Severn SAC/ SPA/ Ramsar and Walmore Common
Brockworth SPA/Ramsar are downstream so there is the potential for
Urban Extension, impacts alone on water quality. Horsbere Brook should be
Gloucester) protected and retained and any proposal for
development should ensure that impacts on water quality
1550 and resources are minimised. It is considered that suitable
dwellings. mitigation will be available to address the potential likely
significant effect of development alone on water quality.
Potential in-combination effects are considered in
Appendix IV and Section 4 of the HRA (AA) Report.
SA1 –Strategic Site is approximately 6.5 km away from Dixton Woods SAC
Allocations and therefore there are unlikely to be any significant
Policy effects alone with regard to recreational activity. The River
Swilgate and Hyde River flow through the site and
A5 – North West eventually into the River Severn. The River Severn SAC/
Cheltenham SPA/ Ramsar and Walmore Common SPA/Ramsar are
(Previously downstream so there is the potential for impacts alone on
known as A5 – water quality. The Rivers flowing through the site should be
North West protected and retained and any proposal for
Cheltenham development should ensure that impacts on water quality
Urban Extension, and resources are minimised.
Cheltenham)
Potential in-combination effects are considered in
4785 Appendix IV and Section 4 of the HRA (AA) Report.
dwellings.
23 ha of
employment
land.
SA1 –Strategic Site is situated to the south of Cheltenham, adjacent to the
Allocations existing settlement. The Cotswold Beechwoods SAC lies
Policy approximately 5.5 km away to the South West of the site.
Need to consider potential impacts of development on
A6 – South the A46 which runs along the eastern boundary of the site
Cheltenham and adjacent to the SAC. Potential for increased levels of
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